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Masterbrand Cabinets, Inc., d/b/a Omega Cabinetry and Ace American Insurance Company v. Chad Simons
20-1635
Iowa Ct. App.
Sep 22, 2021
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Background

  • Chad Simons, employed by Masterbrand/Omega since 1997, sustained a work-related ruptured right quadriceps tendon in November 2015 and underwent surgery in February 2016.
  • Dr. Jason Stanford (selected by Omega) performed the surgery; Simons completed PT and was discharged at maximum medical improvement (MMI) in August 2016.
  • Simons received an award of permanent partial disability after arbitration; the workers’ compensation commissioner affirmed on intra-agency appeal; the district court upheld the commissioner; Omega appealed.
  • Omega argued the injury was a scheduled loss to the leg (knee/quadriceps) and not an unscheduled, whole-body disability; Simons and the commissioner maintained the impairment extended beyond the scheduled member to the body as a whole.
  • Multiple physicians (including an IME by Dr. Delbridge and Omega’s own expert) and Simons’s testimony supported right-hip loss of motion/strength and functional limitations; the commissioner found those opinions more persuasive than the surgeon’s narrower view.
  • The court reviewed agency legal interpretations de novo where appropriate and factual findings for substantial evidence, and affirmed the commissioner’s whole-body impairment ruling.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the quadriceps-tendon injury is a scheduled leg loss or an unscheduled, whole-body disability Effects of the injury impaired the body as a whole; benefits should be unscheduled Injury situs is the leg (knee/quadriceps), therefore scheduled-loss benefits only Commissioner and courts held unscheduled whole-body disability; agency interpretation was proper and statute liberally construed
Whether substantial evidence supports a finding of whole-body impairment (hip involvement) Multiple doctors and Simons’s credible testimony show right-hip loss of motion/strength and functional limitations tied to the work injury Surgeon opined injury was isolated to the knee/quadriceps; Omega contends record shows no hip injury Substantial evidence supports commissioner’s findings; credibility and weight of expert opinions were for the factfinder; affirmed

Key Cases Cited

  • Sladek v. Emp. Appeal Bd., 939 N.W.2d 632 (Iowa 2020) (standard of review for judicial review under the Iowa Administrative Procedure Act)
  • Neal v. Annett Holdings, Inc., 814 N.W.2d 512 (Iowa 2012) (when agency lacks clear interpretive authority, court reviews legal interpretation)
  • Waldinger Corp. v. Mettler, 817 N.W.2d 1 (Iowa 2012) (workers’ compensation statute construed liberally for employee benefit)
  • Barton v. Nevada Poultry Co., 110 N.W.2d 660 (Iowa 1961) (distinction between "injury" and "industrial disability" and scope of paragraph (u))
  • Lauhoff Grain Co. v. McIntosh, 395 N.W.2d 834 (Iowa 1986) (difference between scheduled-member benefits and paragraph for unscheduled disabilities)
  • Evenson v. Winnebago Indus., Inc., 881 N.W.2d 360 (Iowa 2016) (factual findings upheld if supported by substantial evidence)
  • Larson Mfg. Co. v. Thorson, 763 N.W.2d 842 (Iowa 2009) (appellate review focuses on whether substantial evidence supports commissioner findings)
  • Dunlavey v. Econ. Fire & Cas. Co., 526 N.W.2d 845 (Iowa 1995) (credibility and weight of testimony are for the factfinder)
  • Ideen v. Am. Signature Graphics, 595 N.W.2d 233 (Neb. 1999) (test focuses on location of residual impairment, not site of original injury)
Read the full case

Case Details

Case Name: Masterbrand Cabinets, Inc., d/b/a Omega Cabinetry and Ace American Insurance Company v. Chad Simons
Court Name: Court of Appeals of Iowa
Date Published: Sep 22, 2021
Docket Number: 20-1635
Court Abbreviation: Iowa Ct. App.